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Category Breakdown Category Number of Questions Sanctions Compliance 7 Sanctions Screening 2 Enhanced Due Diligence / Trade and Sanctions 1 TOTAL 10 Question #:1 - [Sanctions Compliance] In accordance with the Office of Foreign Assets Control 50% Rule, which entities would be considered sanctioned even if not listed on the Specially Designated National (SDN) List? (Select Three.) A company with an SDN holding a 98% stake in it A company with an SDN holding a 35% stake in it, and another SDN holding a 15% stake in it A company with an SDN holding a 20% stake in it, and another SDN holding a 25% stake in it A company with an SDN holding a 12% stake in it, another SDN holding an 18% stake in it, and another SDN holding a 28% stake in it A company with an SDN holding a 45% stake in it, and another SDN holding a 3% stake in it A company with 10 SDNs, each holding a 4% stake in it Answer: A B D Explanation Under the , an entity must be treated as a Specially Designated National (SDN) — even if OFAC 50% Rule not named on the SDN List — when: One SDN owns 50% or more of the entity , OR Multiple SDNs collectively own 50% or more of the entity (ownership must be aggregated). Applying this rule: A: 98% ownership by a single SDN # Blocked (exceeds 50%). B: 35% + 15% = # Blocked (meets 50%). 50% aggregate ownership by two SDNs C: 20% + 25% = , which does meet the threshold # Not blocked. 45% not D: 12% + 18% + 28% = # Blocked (exceeds 50%). 58% aggregate ownership by SDNs E: 45% + 3% = , which is below 50% # Not blocked. 48% F: 10 SDNs × 4% = , which is below 50% # Not blocked. 40% ACAMS - CGSS Certs Exam 2 of 8 Pass with Valid Exam Questions Pool A. B. C. D. A. Thus, only A, B, and D meet or exceed the 50% aggregate ownership requirement defined by OFAC. References: OFAC “50 Percent Rule” Guidance: Entities owned 50% or more, directly or indirectly, singly or in the aggregate by one or more SDNs, are considered blocked. OFAC Ownership and Control Interpretive Guidance detailing aggregation of SDN ownership percentages. Question #:2 - [Sanctions Compliance] According to the Office of Foreign Assets Control guidance on virtual currency, in which way can virtual currencies be blocked? Return the currency to the exchange owner's domain. Move the virtual currency to a centralized wallet where other blocked currencies are being held. Transfer to traditional fiat currency and hold such blocked property in an interest-bearing account. Deny access to the virtual currency and report blocked assets. Answer: D Explanation OFAC guidance clarifies that blocking virtual currency means preventing any access, transfer, or of the asset by the sanctioned party. The entity holding the virtual currency must: withdrawal Deny access to the wallet or virtual asset, and Report the blocked property to OFAC in accordance with reporting rules. Virtual currencies are not “returned” (A), not necessarily moved to a pooled wallet (B), and are not converted to fiat unless authorized (C). References: OFAC Virtual Currency Guidance on blocking and reporting. Requirements for preventing access to digital assets belonging to sanctioned persons. Question #:3 - [Sanctions Compliance] The Office of Foreign Assets Control has focused on sanctions risks in mergers and acquisitions by undertaking which action? Considering enforcement actions against companies that knowingly fail to do sufficient due diligence ACAMS - CGSS Certs Exam 3 of 8 Pass with Valid Exam Questions Pool B. C. D. A. B. C. D. Pursuing enforcement actions against companies that fail to do sufficient due diligence Putting out joint guidance with the Securities and Exchange Commission that highlights the sanctions risks of mergers and acquisitions Discouraging mergers and acquisitions in its framework for compliance commitment Answer: B Explanation Sanctions and Compliance Domains outline that OFAC has explicitly emphasized the importance of pre- and post-acquisition sanctions due diligence in mergers and acquisitions. OFAC has pursued enforcement actions against companies that failed to conduct adequate sanctions due diligence or did not integrate compliance controls after acquiring foreign subsidiaries. OFAC’s enforcement history shows cases in which companies inherited violations because they continued business through acquired entities that were already engaged in sanctioned conduct. OFAC clearly identifies failure to conduct sufficient sanctions due diligence as grounds for enforcement. It does not merely “consider” such actions, nor has it issued joint SEC guidance to warn about MandA sanctions risks. OFAC also does not discourage mergers and acquisitions; instead, it stresses compliance integration and strong due diligence. References from Sanctions and Compliance Domains: OFAC expectations for sanctions due diligence in mergers and acquisitions. Enforcement actions taken for failure to conduct adequate pre-acquisition and post-acquisition compliance reviews. Compliance requirements for inherited liabilities through acquired subsidiaries. Question #:4 - [Sanctions Screening] A compliance officer needs to make a decision regarding an organization's sanctions screening process. Which decision is correct? Exclude vendors and other intermediaries from the screening. Include only customers and their transactions in the screening. Include all business activities of the organization in the screening. Exclude beneficial owners of distributors from the screening. Answer: C Explanation ACAMS - CGSS Certs Exam 4 of 8 Pass with Valid Exam Questions Pool A. B. C. D. E. F. Sanctions and Compliance Domains state that screening must be applied to all relevant business activities and relationships that can expose an organization to sanctions risk. This includes customers, vendors, intermediaries, distributors, beneficial owners, and any party involved in transactions, supply chains, or service delivery. Limiting screening only to customers is inconsistent with sanctions compliance expectations. Excluding vendors, intermediaries, or beneficial owners can expose an organization to significant sanctions violations due to indirect dealings with sanctioned parties. Comprehensive coverage of all business activities is the standard approach in an effective sanctions compliance program. References from Sanctions and Compliance Domains: Requirements for comprehensive sanctions screening across all relevant business relationships. Inclusion of customers, intermediaries, vendors, distributors, and beneficial owners. Risk-based approach requiring full coverage of business activities to prevent indirect sanctions exposure. Question #:5 - [Sanctions Compliance] The Office of Foreign Assets Control has designated which types of high-risk persons or entities in the digital asset ecosystem? (Select Three.) Persons hacking and stealing cryptocurrency Cryptocurrency exchanges Mixers Software developers Credit unions Central banks Answer: A B C Explanation OFAC has designated: • involved in cryptocurrency theft. Hackers and cyber actors • facilitating illicit transactions or supporting sanctioned jurisdictions. Cryptocurrency exchanges • known to anonymize blockchain transactions and facilitate laundering and sanctions Mixers (tumblers) evasion. ACAMS - CGSS Certs Exam 5 of 8 Pass with Valid Exam Questions Pool A. B. C. D. Software developers (D) are generally not designated unless directly linked to illicit activity. Credit unions and central banks are not typical OFAC digital-asset designations. References: OFAC digital asset designations (e.g., mixers, DPRK cyber actors). Sanctions risk indicators in the virtual currency sector. Question #:6 - [Sanctions Compliance] Which unit function has been identified as critical to managing sanctions risks? Third-party due diligence firms Credit risk management Audit and testing Human resources Answer: C Explanation Within sanctions compliance programs, one of the core components identified as essential for effective management of sanctions risks is audit and testing. The Sanctions and Compliance Domains describe that sanctions programs require independent review, periodic testing, and validation to assess whether internal controls, screening systems, and escalation processes operate effectively. Audit and testing units provide the independent assurance needed to detect program weaknesses, evaluate the adequacy of controls, and confirm compliance with regulatory requirements. Sanctions frameworks emphasize that the ability to identify deficiencies, monitor adherence to procedures, evaluate risk-control effectiveness, and ensure continuous improvement is fundamental to maintaining a sound sanctions compliance environment. Audit and testing functions are responsible for reviewing the design and effectiveness of sanctions policies, validating the performance of screening tools, and ensuring corrective action is taken where deficiencies are found. For this reason, the function is identified as critical for managing sanctions risks across financial institutions and regulated entities. References from Sanctions and Compliance Domains: Requirements for independent auditing and testing as a core component of an effective sanctions compliance program. Expectations for regular review of sanctions controls, screening performance, and risk assessment processes. Emphasis on independent validation to ensure ongoing compliance with regulatory obligations and to detect gaps in sanctions controls. ACAMS - CGSS Certs Exam 6 of 8 Pass with Valid Exam Questions Pool A. B. C. D. A. B. C. D. Question #:7 - [Sanctions Screening] A financial institution's decision to adjust the degree of sensitivity of a screening tool should be based on its transaction volume and: number of staff. personnel training. risk assessment. management commitment. Answer: C Explanation Sanctions and Compliance Domains state that screening calibration must be tied directly to a financial institution’s sanctions , which evaluates products, customer base, geography, delivery risk assessment channels, and transaction volume. Sensitivity adjustments must be justified by an institution’s assessed sanctions exposure. Staff levels or training do not determine screening thresholds; these are operational considerations. Management commitment supports governance but does not form the technical basis for calibration decisions. References: Screening calibration tied to sanctions risk assessments. Threshold adjustments must reflect actual sanctions exposure and transaction characteristics. Question #:8 - [Sanctions Compliance] In the event of a sanctions violation, the inclusion of a sanctions clause in a trade contract can: define which sanctioned elements are prohibited in the execution of the contract. enforce the contract if sanctions are imposed on any of the parties. identify the liability for any fines related to sanctioned entities. act as a specific license allowing the contract to be fulfilled. Answer: A Explanation Sanctions and Compliance Domains state that sanctions clauses in trade contracts are used to: ACAMS - CGSS Certs Exam 7 of 8 Pass with Valid Exam Questions Pool A. B. C. D. E. • clarify prohibited activities, • define obligations of the parties in case sanctions become applicable, and • ensure business partners understand compliance expectations. A sanctions clause a contract when sanctions apply (B), cannot enforce cannot assign liability for (C) beyond legal requirements, and (D). Only regulators (e.g., regulatory fines cannot operate as a license OFAC, EU authorities) can authorize activities by issuing licenses. References: Trade contract sanctions clauses and their function. Legal requirements surrounding sanctions clauses and regulatory authority. Question #:9 - [Enhanced Due Diligence / Trade and Sanctions] A bank is offering a credit line for a trade transaction to a commercial client that is based in a country that shares its border with a sanctioned country. To which should a financial institution apply enhanced due diligence? (Select Two.) The ultimate beneficial owners of the exporter and importer. The shipment details because there are countries subject to international sanctions in the client's region. Public domain searches of the client to confirm the client's industry. The commercial terms of the credit to ensure the terms are not prohibited under Sectoral Sanctions’ extension of debit or credit arrangements. The pricing of the goods to see if they are reasonably in line with market value, determined through publicly available sources. Answer: A B Explanation Enhanced due diligence is required when trade transactions involve jurisdictions near sanctioned countries due to the increased risk of transshipment, diversion, and sanctions evasion. Sanctions and Compliance Domains highlight two core focus areas: • verifying the identities and ultimate beneficial owners of all involved parties, and • validating the shipment details, including routing, goods description, and movement patterns. These elements are critical where geographic proximity raises sanctions exposure. While reviewing commercial terms and pricing may be part of general trade finance due diligence, the primary sanctions- specific EDD requirements focus on beneficial ownership and shipment details. ACAMS - CGSS Certs Exam 8 of 8 Pass with Valid Exam Questions Pool A. B. C. D. E. References from Sanctions and Compliance Domains: Enhanced due diligence expectations for trade involving high-risk regions. Requirements to verify UBOs to detect potential sanctioned ownership. Importance of shipment route verification to detect diversion to sanctioned jurisdictions. Question #:10 - [Sanctions Compliance] Which are the primary sources of information for a sanctions investigation? (Select Two.) Transaction activity review Government blocked persons and export restriction lists Internal bank correspondence News headlines Social media publications Answer: A B Explanation Sanctions investigations rely primarily on the factual evidence contained in transaction activity and on authoritative, government-issued sanctions lists. Transaction details provide information on counterparties, payment paths, goods, and purpose. Official blocked-person lists such as OFAC, EU, UN, and national export- control lists provide the authoritative basis for sanctions matching. News, social media, and internal correspondence may supplement context but are not primary sources. References: Transaction activity as primary investigative data. Mandatory reliance on official sanctions and export-restriction lists. About certsout.com certsout.com was founded in 2007. We provide latest & high quality IT / Business Certification Training Exam Questions, Study Guides, Practice Tests. We help you pass any IT / Business Certification Exams with 100% Pass Guaranteed or Full Refund. Especially Cisco, CompTIA, Citrix, EMC, HP, Oracle, VMware, Juniper, Check Point, LPI, Nortel, EXIN and so on. View list of all certification exams: All vendors We prepare state-of-the art practice tests for certification exams. You can reach us at any of the email addresses listed below. Sales: sales@certsout.com Feedback: feedback@certsout.com Support: support@certsout.com Any problems about IT certification or our products, You can write us back and we will get back to you within 24 hours.